08 March 2013

EBF Key Information Document on Bank Accounts

The EBF summarised analyses on transparency and comparability of bank account fees, on switching of bank accounts, and on access to a basic payment account. It listed three top recommendations.

Summary of EBF analyses:

• Bank account fees, transparency and comparability: the EBF supports clear, accessible and comparable information on fees that allow consumers to make informed choices regarding several payment account offers. Given the numerous national initiatives, the question remains whether there is a case at EU level, and if so, whether this should be outside the Payment Services Directive (PSD), currently under review.
• Bank account switching: the EBF is committed to supporting bank account switching and with this, facilitating consumer mobility. The EBF believes that the Common Principles on bank account switching agreed at the European Banking Industry Committee (EBIC) level constitute the right approach. This said, the EBF acknowledges the potential to improve efficiency of the implementation further by appropriate initiatives at national level. Considering the very limited number of cases of opening cross-border bank accounts, imposing switching mechanisms, at cross-border level, would be disproportionate.
• Access to basic payment account: the EBF fully understands the objectives of financial inclusion and agrees with the European Commission on the need for consumers to access financial services to enable them to participate fully in the economic and social life of modern society. The EBF argues it is important to make a distinction between the social (access to Basic Payment Account) and internal market (cross-border access for EU residents) policy approaches. In the EBF’s views, any limited product or price intervention regulation would only be justified if it tackled financial exclusion.
• The EBF welcomes measures aimed at restoring confidence in the banking sector. However, it is to be expected that EU regulatory policy solutions are built on the strengths of evidence-based tools assessing the need for EU regulatory measures.

EBF top recommendations

• Beyond the implementation of the Payment Services Directive (PSD), many Member States and banking communities have already taken on a number of initiatives, at national level, so as to enhance transparency and comparability of bank account features. In order to give these initiatives a chance to succeed, the EBF does not consider appropriate further European Union (EU) legislative proposals at this stage. In any event, any initiative at the EU level can only be proportioned and limited to high level principles, which would then have to be worked out and implemented at national level.
• Improved efficiency of the European Banking Industry Committee‘s (EBIC) Common Principles on bank account switching, should not be driven by legislation, but by enhanced awareness and communication between the interested stakeholders. Owing to the different conditions and particularities of the national markets in the EU, the Common Principles should ideally remain voluntary or, at least not be changed content wise.
• In the EBF’s view, if the very purpose of the right to a basic bank account is to combat financial exclusion, this right should only be granted to consumers resident in their respective countries, and who do not already hold a regular payment account.

Full document

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